As seen in the affidavit and in the previous chapter, the Church of
Scientology and its Office of Special Affairs have never abandoned the
use of intelligence operations or illegal activities if such actions
would be helpful to achieve Scientology's goals.

The head of RTC, David Miscavige stated in a sworn declaration from
February 8th, 1994 [Exh. No. 377, Excerpt]:

" …As a direct result of the GO corruption and its ultimate overthrow,
the Church embarked on a complete corporate reorganization, in part to
prevent such criminality from ever occurring again and to make sure a
‘new GO' could never come about. This is where CSI and RTC came into
existence and the reasons for their place in the Church hierarchy are
clearly stated in the Church of Scientology International reference
book What is Scientology?[:]

"November 1, 1981 – The Church of Scientology International was
founded, signaling a new era of Scientology management. A strong
standardized corporate structure was required to facilitate the rapid
expansion of Scientology and maintain high ethical standards in a
widespread international network of churches. …"

The new management under Miscavige did reorganize Scientology's
corpotate structure and a "new GO" in fact did not come about. Since
its dissolution in 1983, its intelligence functions and criminal
operations have been continued by the Office of Special Affairs, under
the direction and control of the "Church of Scientology International"
and the "Religious Technology Center," and financed by the "Flag
Service Organization, Inc." and the "Church of Scientology Western
United States."

What I have mentioned in this affidavit are the cases of criminal
conduct, which are exemplary for Scientology's conduct and for which I
possessed sufficient and explicit evidence, mainly using Scientology's
own internal documents, as I did not want to rely on declarations by
ex-Scientologists. For this reason I have only used one time an
extract from a declaration of a former Scientologist (ex-RTC official
Vicki Aznaran) as supporting evidence.

There is far more to say about the Church of Scientology's past and
present un-ethical, illegal and non-charitable activities, that could
be included in siuch an affidavit. Therefore, in order to have a more
complete picture of Scientology's activities I will add a few
instances that I find characteristic of the organization's general
criminal conduct (Example 1) and that I think are exemplary for the
organization's dealing with criticism in general (Example 2).

Example 1: When the Scientology organization came under a lot of
scrutiny by the German government during the mid-1990s, the German
branch "Office of Special Affairs" was desperately looking for allies
among various muslim organizations. The goal was to form an alliance
with other "presecuted minority religions."

While moderate associations of muslims showed no interest in any
cooperation with them, the Scientologists found an ally in "IG Milli
Görüs" (IGMG) a fundamentalist Turkish group, which has been under
surveillance by the German intelligence service for its radical,
anti-democratic and anti-Semitic views and its various contacts with
other groups. IGMG has maintained and supported contact with muslim
rebel groups in the Caucasian region as well as with radical groups in
Africa, including the Egyptian "Muslim Brotherhood."

This did not disturb the Scientologists and its Office of Special
Affairs," who began to consult the officials of the IGMG, Mehmet
Erbakan and Hasan Özdogan, in their real estate dealings and legal
affairs. In return, the IGMG joined Scientology's "Peace Movement
Europe," an association composed of members of "minority religions,"
which was founded and led by President Rosemarie Mundl, an OSA
operative and official of the German CCHR-branch.

In 1994/'95 the cooperation between Scientology and the IGMG
intensified. Scientologists held seminars at IGMG's headquarters in
Cologne and Özdogan invited his new allies to strategy meetings in
Islamic countries. One of these invitations led the Scientologists,
including Mundl, to a visit of the annual celebrations of revolution
in Libya [Exh. No. 378]. There the delegation with members of the
above-mentioned "Peace Movement" could watch a tank parade before they
were personally welcomed by Libya's ruler Muammar Qaddafi.

When the contacts between the Scientologists and IGMG were made public
in 1996 and 1997, the Turkish muslims quickly renounced their contacts
and distanced themselves from the ideology of Scientology. Now Özdogan
publicly declared about the Scientologists and their activities:

"They have have nothing to do with religion and are completely secular
oriented. Scientology is solely maintaining an American make-money
ideology."

Example 2: On June 16th, 1998 NBC's "Dateline" aired a documentary
called "The Crusader" that portrayed the Scientology-critic Robert
Minton from Boston. Included in the show were segments extracted from
interviews the host John Hockenberry had held with the chief of the
"Office of Special Affairs International" Michael Rinder.

In two segments Hockenberry discussed Scientology-founder Hubbard's
policy regarding criticism of Scientology. Fully aware that the show
would be aired to a national audience, Rinder was not shy to defend
Hubbard's statements that "every critic of Scientology is a criminal"
and deliberately compared critic Minton with terrorist Timothy
McVeigh:

HOST JOHN HOCKENBERRY: "L. Ron Hubbard says, ‘We do not find critics
of Scientology who do not have criminal pasts. Over and over we prove
this. we have this technical fact - those who oppose us have crimes to
hide.' Do you believe that?"
RINDER: "Sure."

HOCKENBERRY: "People who oppose you are undoubtedly criminals?"

RINDER: "I believe that, yeah."

Voice-over: "And that's straight from the writings of Scientology
founder L. Ron Hubbard. The maxim is, ‘When under attack, attack,' he
once wrote. ‘It is only those people that have crimes that will attack
us, and they will so back off for fear of being found out when
attacked back.'"

HOCKENBERRY: "That sounds a little paranoid, Mike."

RINDER (chuckling): "Maybe so, John, but I, I - …"

HOCKENBERRY: "Why aren't they just people who disagree with you?"

RINDER: "Well, I think that there's a difference between people who
disagree and people who are on some sort of an active crusade or a
campaign to attempt to destroy the church. I think that that's - …"

HOCKENBERRY: "Well, L. Ron Hubbard here says that the difference is
that they are criminals invariably, in their past are crimes."

RINDER: "Yeah, I think that that's true."

HOCKENBERRY: "Now, he also says, ‘Try it on your next critic, finding
their crimes. Like everything else in Scientology, it works.'"

RINDER: "I think that you could characterize it that way, yeah. I
think that, that looking into the motivation of people as to why it is
that they are seeking to destroy the church is a valid thing to do."

RINDER: "I don't know what motivates this guy [Robert Minton], I don't
know what. But on the other hand if you asked me, do I know what
motivated Timothy McVeigh to go blow up a building because his view is
that the people sitting inside that building are violating the rights
of citizens of the United States, I don't know why he does that. I, I
don't know that you could - …"

RINDER: "No, motivation. Like, what is it that motivates someone to,
to do that? I don't know. I don't know how you tell someone does that
before they do it."

HOCKENBERRY: "All right, but you very deliberately compared Bob Minton
to Timothy McVeigh."

RINDER: "All right."

On December 28th, 1997 CBS' "60 Minutes" aired a documentary about the
take-over of the "Cult Awareness Network" (CAN) by the Church of
Scientology. CAN had been a non-profit association that had informed
the general public about cults and had been one of the most vocal
critics of Scientology in the United States.

The Church of Scientology had run several intelligence operations
against CAN and its members and was, in the end, successful in driving
it into bankruptcy through a false imprisonment suit. CAN was found
guilty in 1996 by a Californian jury to be co-responsible for the
deprogramming attempt on a young man, Jason Scott, who had been a
member of a controversial bible-group. During the trial Scott had been
represented by Scientology-lawyer and OSA-member Kendrick Moxon. At
the bankruptcy proceedings, that followed the verdict in the
Scott-trial, a Scientologist, Steven Hayes, bought with $ 20,000 the
right for using CAN's name and logo and set up a counseling service
under the same name that was run by Scientologists.
The "60 Minutes"-show also featured some of the intelligence
operations that had been conducted prior to CAN's demise and which
included the hiring of private investigators to find dirt in the
private lives of CAN officials. Cynthia Kisser, as the national
executive director of CAN, had been a primary target for such
activities. In one segment host Lesley Stahl interviewed Kendrick
Moxon about his hiring of private detectives to investigate Kisser.
Moxon could not resist to smear her with the allegation, although he
knew it was false, that Kisser had been a topless dancer prior to her
employment at CAN:

HOST LESLEY STAHL: "We are told, Mr. Moxon - …"

KENDRICK MOXON: "Yes."

STAHL: "… - that a small army of private investigators was hired by
your law firm to go out and dig up dirt on members of CAN, Cynthia
Kisser specifically, and anything else they could find. Is that true?"

MOXON: "I - no, it's not true."

STAHL: "Now, a lot of lawyers hire private eyes to dig up dirt on
people - …"

MOXON: "No - …"

STAHL: "…- I mean, now, we were even hearing - …"

MOXON: "- I don't know. I know … I've heard that people do that, and I
know that the media does that, but I don't know that a lot of lawyers
do that. I don't do that."
Voice-over: "He acknowledges using private detectives, but not for the
purpose of digging up dirt. But former private eye Michael Shomers
says Moxon's law firm hired him to do just that."

MICHAEL SHOMERS: "Find the sleaze, to find the hidden alcoholism, to
find the hidden drug abuse, if that was the case."

STAHL: "The sex life."

SHOMERS: "The sex lives."

STAHL: "Bad debts."

SHOMERS: "Correct."

Voice-over: "He says he got his marching orders during a meeting right
in the Scientology church in Washington, DC. He says a staffer briefed
him on CAN, and jotted down notes that Shomers kept. He says he was
told to investigate CAN and its purported allies: IRS officials, and
congressman Henry Waxman of California. And he was told to dig up
enough dirt on Cynthia Kisser to destroy her reputation and intimidate
her into silence.

STAHL: "Did you tell our producer that you didn't believe that was
true?"

MOXON: "I told your producer that I thought, looking at Cynthia
Kisser, it seemed improbable that she could have been a topless dancer
because of the way she looks."

Voice-over: "Yet despite his own view and the evidence from
investigator Shomers, Moxon, also a minister in the Church, persisted
in bringing it up."

MOXON: "I mean, we've got a declaration already indicating that she
had been a topless dancer."

STAHL: "I can't believe you're continuing to talk about her being a
topless dancer!"

MOXON: "Why? That was one of the allegations - …"

STAHL: "But you even said you don't even think she was one. It's
character assassination."

MOXON: "I don't - that - Lesley, there is a declaration from a woman
swearing that she was a topless dancer."

STAHL: "Were you a topless dancer?"

KISSER: "No, and later the person that they claimed told them that
retracted it … issued a retraction saying that it wasn't true."

In another show of "60 Minutes" from December 22nd, 1985 L. Ron
Hubbard's false credentials that had been attributed to him by the
organization were discussed. At that time the so-called
Armstrong-trial had received a lot of publicity. Armstrong, a former
archivist of Hubbard was sued by the Church of Scientology for
allegedly stealing private documents from Hubbard. The suit was
dismissed in the fall of 1984 and judge Breckenridge's comments
received afterwards attention as he had stated that Hubbard was a
pathological liar and had characterized both the founder and its
organization as paranoid and schizophrenic.

Besides talking to ex-Scientologists and the former Hubbard biographer
Omar Garrison, host Michael Wallace also interviewed the President of
the "Church of Scientology International," Heber Jentzsch and then
CSI's lead attorney Earle Cooley at Scientology's headquarters in Los
Angeles. In an apparent attempt of intimidation Wallace and his crew
was surrounded by a hundred Scientologists and several cameras during
his interview.

When Wallace confronted Jentzsch with Hubbard's writings about the
founder's proposed treatment of Scientology's critics, Jentzsch went
into a verbal counter attack with which he unwillingly confirmed
Breckenridge's comments about the organization's actual state of mind:

Voice-over: "The current church leadership has located the Scientology
headquarters in L. A. We wanted to know what they had to say. And the
Scientologists, although unhappy with our report in 1980, finally
agreed to an interview. But this time, the Scientologists, convinced
that we were out to attack their church, arranged for several of their
videotape cameras to be
trained on us at all times during the session. Church President, the
Reverend Heber Jentzsch, had his attorney, Earl Cooley, sitting at his
side and almost a hundred Scientologists were called in as witnesses."

JENTZSCH: "Scientology is the only road to total freedom, whether you
agree with it or not, that is the truth. And ‘he' has outlined the way
to do it."

HOST MICHAEL WALLACE: "The … only … road … to … total … freedom.
That's the only road?"

JENTZSCH: "I said, the only road to ‘total' freedom."

WALLACE: "Yes. What does that mean: ‘only road to total freedom'?"

JENTZSCH: "Oh, is there some word there you don't understand?"

WALLACE: "I … I … I don't understand the concept. I mean … what kind
of freedom are we talking about?"

JENTZSCH: "Spiritual freedom."

WALLACE: "And, as for the founder, L. Ron Hubbard?"

JENTZSCH: "I think he's probably one of the greatest men who ever
lived. I think that what you see and hear are … all through this place
are recognitions for what he has done in the area of drug
rehabilitation, what he has done in areas of education, recognition of
cities and mayors and governors and so forth and individuals whose
lives have been changed."

Voice-over: "But if Hubbard is a man of enlightenment, he is also a
man who is obsessed with his perceived enemies. ‘Attack the attacker,'
he writes. ‘If Scientology is attacked on some vulnerable point,
always find or manufacture enough threat to cause them to sue for
peace. Always attack, don't ever defend.' According to former church
members, it is writing like this that inspired bizarre plots, like the
ones against Paulette Cooper and numerous others. But when I put some
of that to the Reverend Jentzsch, he accused us of coming to the
defense of Scientology's enemies."

JENTZSCH: "We say when Pearl Harbor happened, you'd be the first guy
going over there to represent the Japanese cause he probably bruised
his knee when he killed all those Americans. You'd say, 'Oh, don't
attack the attacker.' Just going to wipe you out, you know. Just a
bunch of poor Japanese bombing? 3000 miles off course. Mike Wallace,
that's great. That's real great rhetoric."

Voice-over: "Then the Reverend Jentzsch turned to the scriptures to
try to convince us that we were taking things out of context."
JENTZSCH: "The Torah has said ‘If one comes to kill you, rise up and
kill him first.' … [Several other quotes, including Exodus 2, 11:14] I
can just take it and turn it back to you and say, ‘You're a Jew, how
do you respond to this thing?' I don't think that's fair. I think that
is a despicable activity by anyone to take it out of context. And I
can go through the whole bible and lift it out and make it look just
as crazy, just as weird, as you're trying to do here. With millions
and millions of word in print in a religion and you can take out two
words or you can take out a sentence and you can somehow try to bring
it down to that."

Voice-over: "In the course of reporting this story it became apparent
to us that the Reverend Jentzsch is persuaded that 60 Minutes itself
is somehow involved with others in a plot to destroy Scientology."

JENTZSCH: "You may not like our religion. You may try to castigate it.
You may try to denigrate it. You may try to bring down the image of
Mr. Hubbard, but you cannot change what has happened in the hearts and
minds of every single Scientologist who has had benefit from the man
and what he has done."

Voice-over: "And:"

JENTZSCH: "We're here. We're here after 60 Minutes disappears and the
electrons are erased off the tape, we'll still be here."

Voice-over: "What about the credibility of Homer Shomer and the other
former Scientologists who are now speaking out? The Scientologists
claim that those former church members were purged from the church, in
effect thrown out, after an internal power struggle. According to the
church's leaders they are all disgruntled and have personal gripes and
so the church says, they are lying. Sullivan, Shomer, Garrison and
others have all been called as witnesses in court about their
experience with Scientology and according to the Reverend Jentzsch the
words of California Superior Court Judge, Paul Breckenridge, who
presided over one of those cases in which the Scientologists were
embroiled. In that case the Scientologists did not testify to all they
told us in this report. Still, Judge Breckenridge found Sullivan,
Shomer and Garrison to be extremely persuasive, to be credible
witnesses. And I read further from the judge's opinion:

‘The organization is clearly schizophrenic and paranoid. And, this
bizarre combination seems to be a reflection of its founder, LRH. The
evidence portrays a man who has been virtually a pathological liar
when it comes to his history, background, and achievements.' The
Reverend Jentzsch says that he has investigated what was the basis for
the judge's decision."

JENTZSCH: "I traced back where that came from, this whole
schizophrenia, paranoia concept that he has. It came from Interpol. At
that time the president of Interpol was a former SS officer, Paul
Dickopf and to find that judge Breckenridge quoted a Nazi SS Officer
as the authority on Scientology, I find unconscionable. You may
support it. I can't support that in any way, shape or form."

The dismissal of the Armstrong-case and the validity of Breckenridge's
memorandum was later affirmed by the Californian Appeal courts.

In my opinion these two examples perfectly demonstrate the criminal
and fanatic mindset behind the Scientology organization.

For Scientology officials it is apparantly totally concurring with
their philosophy and internal policies to get in contact with muslim
extremists or to meet such a questionable figure as Qaddafi, if such a
contact is promising for "future expansion of the religion."

The above mentioned public comments, made by the present officials of
the Scientology management, lack even the slightest form of
introspection or self-criticism. If such behavior is an indication of
the true activities of this organization, which I believe it is, one
can only speculate about the actual number of illegal operations
these individuals were and are involved in.

I declare under penalty of perjury that the aforementioned facts set
forth are true and correct.